| Andy, Do you have comm with the Miramar folks working funding for your trip? Meridith says your plan of meeting on Fri and Mon again with Bell are perfect. Neal Neal A. Puckett, Esq LtCol, USMC (Ret) Puckett & Faraj, PC 1800 Diagonal Rd, Suite 210 Alexandria, VA 22314 703.706.9566 The information contained in this electronic message is confidential, and is intended for the use of the individual or entity named above. If you are not the intended recipient of this message, you are hereby notified that any use, distribution, copying of disclosure of this communication is strictly prohibited. If you received this communication in error, please notify Puckett & Faraj, P.C. at 888-970-0005 or via a return the e-mail to sender. You are required to purge this E-mail immediately without reading or making any copy or distribution. Begin forwarded message: From: "Hatch MAJ Douglas C" <douglas.hatch@usmc.mil> Date: January 31, 2011 11:51:58 AM EST To: "Puckett Neal" <neal@puckettfaraj.com> Cc: "Marshall Maj Meridith L" <meridith.marshall@usmc.mil>, "Faraj Haytham" <haytham@puckettfaraj.com> Subject: RE: Bell Motion Neal, Copy all. I'll be around those dates, thought likely in court on a GP on the 15th. I can do a skeleton of the stip. I'll get something out to you all in a few days. The only piece hanging out there re: Dr. Huff is his travel arrangements. My Marines our doing the "cross-org" of funding right now, so I think we're good to go. Doug -----Original Message----- From: Puckett Neal [mailto:neal@puckettfaraj.com] Sent: Monday, January 31, 2011 8:46 AM To: Hatch MAJ Douglas C Cc: Marshall Maj Meridith L; Faraj Haytham Subject: Re: Bell Motion Doug, Now that makes plenty of sense to me. Never thought you were the nickel and dime type, so that was never an issue. We can work with this. I'm planning a trip out there on the back end of an Okinawa trip second week in Feb. Probably can hammer all this out then. I'll be in town 14-16 Feb. Depart for home on the 17th. I think if we could get Bell to Meridith's office on the 14th, we can probably do stip with him if you can give us an skeleton of what you think you need in it. We can talk about the 125 vs. 120 with him. If we have a deal, evidentiary concessions may not be a problem. Glad we're still talking through this difficult case. Still may want Dr. Huff to testify in pre-sentencing, though. Won't know until he does the eval. Does that look like it's happening this week? Neal Neal A. Puckett, Esq LtCol, USMC (Ret) Puckett & Faraj, PC 1800 Diagonal Rd, Suite 210 Alexandria, VA 22314 703.706.9566 www.puckettfaraj.com The information contained in this electronic message is confidential, and is intended for the use of the individual or entity named above. If you are not the intended recipient of this message, you are hereby notified that any use, distribution, copying of disclosure of this communication is strictly prohibited. If you received this communication in error, please notify Puckett & Faraj, P.C. at 888-970-0005 or via a return the e-mail to sender. You are required to purge this E-mail immediately without reading or making any copy or distribution. On Jan 31, 2011, at 11:37 AM, Hatch MAJ Douglas C wrote: Neal, This may sound strange, but I don't think I'll be able to get less than 27 years. I am seriously not nickel and diming you here--everyone is concerned about the relative ages of Makeisha and GySgt Bell upon his release, and I've done the calculations based on standard good time credit. A 27 year sentence seems to be the magic number (at the low end). If you can get me something in writing, plus a stip, I think I can sell 27 to the CA. I know the charge re: viewing porn was a sticking point. Is he willing to plead guilty to everything else? For example, the sodomies were pled in the alternative--he'd have to plead to the sodomy under 125, not to the 120's pled in the alternative. I also have some very specific evidentiary concessions I'll want in there, and I much to prefer to work that out ahead of time rather than amending the PTA later. I wouldn't ask you to stipulate to admissibility, but there will be several pieces of evidence (affidavits, possibly videos) I'd want to get in without having to lay a foundation; Confrontation would need to be waived is some instances of course. We can always duke out relevance. Either you or Meridith mentioned bringing GySgt Bell's dad out here, and that won't be a problem. What do you think? Doug -----Original Message----- From: Puckett Neal [mailto:neal@puckettfaraj.com] Sent: Monday, January 31, 2011 7:49 AM To: Hatch MAJ Douglas C Cc: Marshall Maj Meridith L; Faraj Haytham Subject: Fwd: Bell Motion Doug, Here ya go. Thanks for making it easy. Now, if you could just get me a 26-yr deal, we could be done with this case without any pain or suffering. Neal Neal A. Puckett, Esq LtCol, USMC (Ret) Puckett & Faraj, PC 1800 Diagonal Rd, Suite 210 Alexandria, VA 22314 703.706.9566 www.puckettfaraj.com The information contained in this electronic message is confidential, and is intended for the use of the individual or entity named above. If you are not the intended recipient of this message, you are hereby notified that any use, distribution, copying of disclosure of this communication is strictly prohibited. If you received this communication in error, please notify Puckett & Faraj, P.C. at 888-970-0005 or via a return the e-mail to sender. You are required to purge this E-mail immediately without reading or making any copy or distribution. Begin forwarded message: From: "Bethany Trujillo" <bethany@puckettfaraj.com> Date: January 31, 2011 10:45:11 AM EST To: "Neal Puckett" <neal@puckettfaraj.com> Subject: Bell Motion Neal, Attached. Bethany N. Trujillo Office Manager/Legal Secretary 1800 Diagonal Road, Suite 210 Alexandria, Va. 22314 bethany@puckettfaraj.com (703) 706-9566 Phone (202) 318-7652 Fax DC × CA × MI × VA www.PuckettFaraj.com <http://www.puckettfaraj.com/> Practice is limited to matters and proceedings before special courts - federal courts - agencies. Confidentiality / Privilege Notice: This transmission, including attachments, is intended solely for the use of the designated recipient(s). This transmission may contain information that is confidential and/or privileged or otherwise protected from disclosure. The use or disclosure of the information contained in this transmission for any purpose other than that intended by its transmittal is strictly prohibited. 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